https://www.taxtmi.com/caselaws?id=773750 ITAT Ahmedabad deleted penalty under section 271(1)(c) imposed on assessee for transfer pricing adjustments. TPO made adjustments regarding manufacturing and trading segments, changing profit level indicators from PBDIT/Sales to PBIT/Sales and modifying comparables and filters. ITAT held that differences in interpretation of transfer pricing methods constitute debatable issues that should not attract penalty. Assessee had furnished complete details in good faith using prescribed TNMM method under section 92C. Tax authorities made no finding that arm's length price computation lacked diligence or good faith. Explanation 7 to section 271(1)(c) governing transfer pricing penalties was neither invoked nor discussed. Following judicial precedents including SC decision in Reliance Petroproducts, ITAT concluded penalty conditions under Explanation 7 were not satisfied and deleted the penalty. en-us Mon, 23 Jun 2025 00:00:00 +0530 Fri, 27 Jun 2025 08:37:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773750 ITAT Ahmedabad deleted penalty under section 271(1)(c) imposed on assessee for transfer pricing adjustments. TPO made adjustments regarding manufacturing and trading segments, changing profit level indicators from PBDIT/Sales to PBIT/Sales and modifying comparables and filters. ITAT held that differences in interpretation of transfer pricing methods constitute debatable issues that should not attract penalty. Assessee had furnished complete details in good faith using prescribed TNMM method under section 92C. Tax authorities made no finding that arm's length price computation lacked diligence or good faith. Explanation 7 to section 271(1)(c) governing transfer pricing penalties was neither invoked nor discussed. Following judicial precedents including SC decision in Reliance Petroproducts, ITAT concluded penalty conditions under Explanation 7 were not satisfied and deleted the penalty. Case-Laws Income Tax Mon, 23 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773750